Comment Analysis · Docket FS-2025-0001

FS-2025-0001-612831

Opposes rescissionA1 strongSubstance 12/24Owed an answerPosted October 7, 2026 On Regulations.gov

In short: The comment documents specific local conditions in the Bitterroot National Forest and Ravalli County, including road mileage comparisons and observed invasive plant spread, while citing specific pages of the Roadless DEIS to argue that the proposed rule relies on top-down executive orders rather than local management.

Scored directly — The comment's whole text was scored on its own.

Scorecard

Each dimension is scored 0–3; the eight sum to the substance score out of 24.

  • Specific placeNames a specific location — from a region down to an exact creek, trail, road, or map reference.
  • Local knowledgeDraws on a first-hand connection to the place — visits, sustained activity, occupation, or a professional role.
  • EA analysisEngages the agency's environmental analysis directly.
  • Analytical gapIdentifies something the analysis fails to address.
  • EvidenceBacks claims with specific facts, data, or research.
  • RequestMakes a specific, actionable request of the agency.
  • AlternativeProposes a different course of action.
  • LegalCites statutes, regulations, or legal obligations.

How hard it is to set aside

A1 strong: Must be answered — it names the law.

Owed an answer on Evidence, Legal.

Standard dismissals it defeats

  • Already addressed The agency says its analysis already covers the point. Defeated when the comment cites the law itself: there is no analysis to cite against a statutory claim.
  • Misreads the proposal The agency says the comment misunderstands what is proposed. Defeated when the comment engages the proposal or a named place directly.
  • No cause and effect shown The agency says the comment asserts a harm without showing how the action causes it. Defeated when the comment shows the mechanism.
  • Outside the scope The agency says the comment asks about a different action. Defeated when the comment is specific and tied to this proposal.
  • Certified not substantive The agency certifies the comment raises nothing substantive. Defeated when the comment alleges illegality, which is substantive by the definition the certification runs on.

Still open to the agency

  • Alternative already eliminated The agency says it considered and eliminated the alternative the comment proposes, with a reason. Cannot be defeated from the comment text alone.
  • Deferred to a later decision The agency says the point belongs to a later, site-specific decision. Cannot be defeated from the comment text alone.
  • Not required The agency says the analysis the comment asks for is not required. Cannot be defeated from the comment text alone.
  • Preference noted The agency notes the comment as a statement of preference and takes no action on it. Cannot be defeated from the comment text alone.

Topics

  • Environmental Protection Biodiversity
    • “Undeveloped roadless areas and Wilderness are part of what defines Montana”
    • “Roads are detrimental to recovering animal species such as Grizzly Bears, Lynx, and Wolverines”
    • “Roadless areas provide corridors for these animals to move about and expand their range”
    • “Roads contribute to... the spread of invasive plants”
  • Water Quality Quantity
    • “Logging and mining can and does have negative effects on stream and river quality”
  • Governance Policy Process
    • “To me this sounds like an expansion of top-down management rather than bottom-up”
    • “I support Alternative 1, no action”
    • “repeatedly blocked from gaining wilderness status by conservative legislatures”
  • Recreation Tourism Public Use
    • “They are what makes our state the envy of people from all over our nation and the world”
    • “Imagine if clearcuts or open mines were allowed around the perimeter of Glacier National Park”

What it names

National Forests
Bitterroot National Forest
Law cited
Executive Order 14153Executive Order 14154Executive Order 14192Executive Order 14225

The comment

Shaded passages are the ones the analysis quoted as evidence for a dimension: Specific placeEA analysisEvidence

Roadless Rule Dear Secretary Rollins, I am writing in opposition to rescinding the 2001 Roadless Rule. I support Alternative 1, no action. Undeveloped roadless areas and Wilderness are part of what defines Montana and other western states. They are what makes our state the envy of people from all over our nation and the world. Without them Montana would be just another place. Unroaded areas contain areas of unique special qualities but are not protected by wilderness designation. Many areas are wilderness study areas (WSA) but have been repeatedly blocked from gaining wilderness status by conservative legislatures. Unroaded areas often provide a buffer zone around our wilderness areas and National Parks and Monuments. Imagine if clearcuts or open mines were allowed around the perimeter of Glacier National Park. It has been stated that the purpose of rescinding the 2001 Roadless Rule is to give control back to the local forests and reduce the burden of Washington’s over regulation. But in the body of the Roadless DEIS the following executive orders are found (pages 19-20 I believe): 1.Executive Order 14192: Unleashing Prosperity Through Deregulation 2.Executive Order 14225: Immediate Expansion of American Timber Production 3.Executive Order 14154: Unleashing American Energy 4.Executive Order 14153: Unleashing Alaska’s Extraordinary Resource Potential To me this sounds like an expansion of top-down management rather than bottom-up especially considering other actions we have seen from the current administration. Lastly, some bullet points to ponder: •The Bitterroot National Forest where I live has 2,246 miles of FS roads. For comparison the county, Ravalli, which is surrounded by the forest only has 1,450 miles of road. •Last spring after winter storms closed FS roads with fallen trees, local citizens opened some roads because the Forest Service lacks the resources to do so. •Forest roads are costly to maintain. That is why many are gated and others are in poor condition. Adding more roads will add to the maintenance cost in addition to the initial cost of construction. •Roads contribute to man-made forest fires, the spread of invasive plants, and can have negative effects on sensitive wildlife. Whenever I walk the forest roads in my area I see many invasive plants competing against native species and spreading outward into the forest. •Logging and mining can and does have negative effects on stream and river quality. •Roads are detrimental to recovering animal species such as Grizzly Bears, Lynx, and Wolverines. Roadless areas provide corridors for these animals to move about and expand their range.

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